New Anti-Laundering Rules May Affect Life Settlement Funds
Law360, New York (September 23, 2015, 11:03 AM EDT) -- Brian T. Casey
Robert E. Underhill
On Aug. 25, 2015, the Financial Crimes Enforcement Network, a bureau of the U.S. Treasury Department, issued for public comment proposed rules requiring investment advisers registered with the U.S. Securities and Exchange Commission to establish anti-money laundering programs and impose reporting obligations with respect to suspicious activity under the Bank Secrecy Act.
Depending on the circumstances and availability of exemptions, managers of life settlement investment funds ("fund managers") may or may not be required to register with the SEC as an investment adviser. Fund managers that are registered with the SEC will be subject to...
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